German Supply Chain Due Diligence Law (LkSG) Declaration of Principles
Declaration of Principles according to the German Supply Chain Due Diligence Law (Lieferkettensorgfaltspflichtengesetz (LkSG)) for PSI Software SE
We, the PSI Software SE, commit to respecting human rights and protecting the environment in our own business operations and in collaboration with our suppliers. As required by the Supply Chain Due Diligence Act (LkSG), we have developed this Declaration of Principles to articulate our commitment to human rights and the environment, and our approach to managing related risks in our own business and collaboration with suppliers.
This Declaration of Principles outlines our guiding principles, explains how we implement the law, describes our risk management process, the grievance procedure, and our efforts towards continuous improvement.
While we/our employees lead by example, we expect our suppliers and other business partners also to commit to respecting human rights, to undertake the establishment of appropriate due diligence processes, and to pass on these expectations to their own business partners.
This declaration of principles applies to PSI Software SE (further PSI) with headquarter in Germany.
International Guiding Principels:
PSI respects international standards and guidelines for the protection of people and the environment. Our understanding of our responsibilities, as well as our human rights due diligence processes, are guided by the following international reference instruments:
- UN Guiding Principles on Business and Human Rights
- Universal Declaration of Human Rights of the United Nations (UN-UDHR)
- The International Labour Organization's (ILO) core labor standards on labor and social standards
- Convention on the Rights of the Child (UN-Child Rights Convention)
- OECD Guidelines for Multinational Enterprises
- Sustainable Development Goals (SDGs)
Responsibility:
We are aware of the importance of clearly defining roles and rights to ensure effective implementation of the Supply Chain Due Diligence Act (LkSG).
We have appointed a human rights officer for PSI with headquarter in Germany who is responsible for monitoring the implementation of the requirements of the law. She can be reached via menschenrechtsbeauftragte@psi.de.
The Executive Board / Management bears the responsibility for compliance with the requirements of the law and regularly informs itself about the implementation of the due diligence obligations.
From our employees, suppliers, and business partners, we expect that they respect essential human and environmental legal norms and advocate for them within their scope of action. This particularly applies to the risks identified in our risk analysis. If they observe related violations without effective remediation, they are encouraged to use the grievance mechanism described in this document.
Implementation:
We strive to comply with our human rights and environmental due diligence obligations by implementing the following measures:
- Conducting regular and event-related analysis of human rights and environmental risk situations, both in our own business area and regarding our suppliers (according to § 5 LkSG).
- Implementing effective preventive measures to counter identified risks and prevent future legal violations (according to § 6 LkSG).
- Setting up a grievance procedure for reporting negative human and environmental impacts, or the risks of such impacts, occurring in our supply chain (according to § 8 and 9 LkSG).
- Comprehensive documentation of our risk assessments, measures, and reporting based on it (according to §10 LkSG).
Risk Analysis:
In the context of our risk management efforts, we carry out regular and ad hoc risk assessments according to § 3 and § 5 of the LkSG. As soon as risks are identified, they are prioritized and addressed considering the severity of the potential impact on those affected, the probability of its occurrence, and the reversibility of the impact.
Based on our analyses, we specifically consider the following types of risks as relevant to our value chain:
- Child labor
- Forced labor and modern forms of slavery.
- Disregard of occupational safety and occupational health hazards
- Disregard of the freedom of association, the right to organize, and the right to collective bargaining.
- Discrimination in employment
- Withholding of appropriate wages
- Illegal land acquisition / violation of land rights
- Commissioning or use of private/public security forces contributing to the violation of human or labor rights due to inadequate instruction or control.
- Pollution of water, soil, and air, which may contribute to the violation of human rights.
- Mercury: violation of a prohibition resulting from the Minamata Convention concerning the use of mercury
- Persistent Organic Pollutants (POPs): violation of the prohibition of production and/or use of substances within the scope of the Stockholm Convention (POP), non-environmentally friendly handling of POP-containing substances
- Hazardous Waste: violation of the prohibition of import and export of hazardous waste under the Basel Convention
Measures:
Once we have identified and prioritized risks, we determine the measures we will take to minimize these prioritized risks. We proactively inform and involve the stakeholders we consider important for the implementation of these measures.
In our own business operations, we clearly and continuously communicate our expectations to employees and work to promptly to eliminate all identified risks.
We also communicate our expectations to our suppliers regarding their contribution towards preventing human rights and environmental risks, promoting their understanding and encouraging them to cooperate.
We refer both to the guiding principles mentioned initially and to the following standards and norms particularly relevant to our company and industry:
- ISO 9001 – Qualitäty Managament
- ISO 27001 – Information Security Management
- ISO45001 – Safety and Health at work.
Furthermore, we strive to address identified risks in collaboration with our suppliers and support improvements in their policies, competencies, and procedures. We also encourage our suppliers to collaborate with their own suppliers, and to pass on our expectations and to promote good practices throughout the entire supply chain.
We regularly monitor and assess the effectiveness of our preventive measures to identify and continuously implement possible improvements.
Grievance Procedure:
We have established an effective grievance procedure for gathering information on human rights and environmental risks that occur in our business operations and supply chain. We have also appointed a Complaints Officer and a Complaints Team. We have regulated further details in the publicly accessible rules of procedure in accordance with Section 8 (2) LkSG.
In designing and implementing this procedure, we particularly focus on the following characteristics:
- Clarity and easy accessibility for anyone who wants to report concerns or suspicions regarding possible human rights and environmental risks in our own business operations and supply chain.
- Confidential handling of all reports, with due care for the privacy and safety of the reporting person.
- Preliminary assessment of reports to determine whether they relate to a potential human rights or environmental risk in our supply chain or our own business operations.
- Thorough investigation of all human rights and environmental grievances and taking appropriate remedial actions to address identified risks.
- Regular feedback to the reporting person on the status of their report and the result of the investigation, as far as this is legally permissible.
- Detailed recording of all reports and investigations, including any remedial measures, and retention of these records.
- Ensuring that whistleblowers are protected from reprisals.
- Training our staff (Complaints Officer and members of the Complaints Team) for responsible and effective handling of reports.
The grievance procedure is accessible in the following way: complains.supply.chain@psi.de.
Continuos Improvemant:
We will regularly review the effectiveness of our risk assessments, our grievance procedure, as well as our prevention and remediation measures, and work towards their continuous improvement. In doing so, we want to ensure that we remain in compliance with relevant laws and international standards on human rights and the environment in the long term.
Berlin, 23.10.2024
PSI Software SE
Declaration of Principles according to the German Supply Chain Due Diligence Law (Lieferkettensorgfaltspflichtengesetz (LkSG)) for PSI Transcom GmbH
We, the PSI Transcom GmbH, commit to respecting human rights and protecting the environment in our own business operations and in collaboration with our suppliers. As required by the Supply Chain Due Diligence Act (LkSG), we have developed this Declaration of Principles to articulate our commitment to human rights and the environment, and our approach to managing related risks in our own business and collaboration with suppliers.
This Declaration of Principles outlines our guiding principles, explains how we implement the law, describes our risk management process, the grievance procedure, and our efforts towards continuous improvement.
While we/our employees lead by example, we expect our suppliers and other business partners also to commit to respecting human rights, to undertake the establishment of appropriate due diligence processes, and to pass on these expectations to their own business partners.
This declaration of principles applies to PSI Transcom GmbH (further PSI) with headquarter in Germany.
International Guiding Principels:
PSI respects international standards and guidelines for the protection of people and the environment. Our understanding of our responsibilities, as well as our human rights due diligence processes, are guided by the following international reference instruments:
- UN Guiding Principles on Business and Human Rights
- Universal Declaration of Human Rights of the United Nations (UN-UDHR)
- The International Labour Organization's (ILO) core labor standards on labor and social standards
- Convention on the Rights of the Child (UN-Child Rights Convention)
- OECD Guidelines for Multinational Enterprises
- Sustainable Development Goals (SDGs)
Responsibility:
We are aware of the importance of clearly defining roles and rights to ensure effective implementation of the Supply Chain Due Diligence Act (LkSG).
We have appointed a human rights officer for PSI with headquarter in Germany who is responsible for monitoring the implementation of the requirements of the law. She can be reached via menschenrechtsbeauftragte@psi.de.
The Executive Board / Management bears the responsibility for compliance with the requirements of the law and regularly informs itself about the implementation of the due diligence obligations.
From our employees, suppliers, and business partners, we expect that they respect essential human and environmental legal norms and advocate for them within their scope of action. This particularly applies to the risks identified in our risk analysis. If they observe related violations without effective remediation, they are encouraged to use the grievance mechanism described in this document.
Implementation:
We strive to comply with our human rights and environmental due diligence obligations by implementing the following measures:
- Conducting regular and event-related analysis of human rights and environmental risk situations, both in our own business area and regarding our suppliers (according to § 5 LkSG).
- Implementing effective preventive measures to counter identified risks and prevent future legal violations (according to § 6 LkSG).
- Setting up a grievance procedure for reporting negative human and environmental impacts, or the risks of such impacts, occurring in our supply chain (according to § 8 and 9 LkSG).
- Comprehensive documentation of our risk assessments, measures, and reporting based on it (according to §10 LkSG).
Risk Analysis:
In the context of our risk management efforts, we carry out regular and ad hoc risk assessments according to § 3 and § 5 of the LkSG. As soon as risks are identified, they are prioritized and addressed considering the severity of the potential impact on those affected, the probability of its occurrence, and the reversibility of the impact.
Based on our analyses, we specifically consider the following types of risks as relevant to our value chain:
- Child labor
- Forced labor and modern forms of slavery.
- Disregard of occupational safety and occupational health hazards
- Disregard of the freedom of association, the right to organize, and the right to collective bargaining.
- Discrimination in employment
- Withholding of appropriate wages
- Illegal land acquisition / violation of land rights
- Commissioning or use of private/public security forces contributing to the violation of human or labor rights due to inadequate instruction or control.
- Pollution of water, soil, and air, which may contribute to the violation of human rights.
- Mercury: violation of a prohibition resulting from the Minamata Convention concerning the use of mercury
- Persistent Organic Pollutants (POPs): violation of the prohibition of production and/or use of substances within the scope of the Stockholm Convention (POP), non-environmentally friendly handling of POP-containing substances
- Hazardous Waste: violation of the prohibition of import and export of hazardous waste under the Basel Convention
Measures:
Once we have identified and prioritized risks, we determine the measures we will take to minimize these prioritized risks. We proactively inform and involve the stakeholders we consider important for the implementation of these measures.
In our own business operations, we clearly and continuously communicate our expectations to employees and work to promptly to eliminate all identified risks.
We also communicate our expectations to our suppliers regarding their contribution towards preventing human rights and environmental risks, promoting their understanding and encouraging them to cooperate.
We refer both to the guiding principles mentioned initially and to the following standards and norms particularly relevant to our company and industry:
- ISO 9001 – Qualitäty Managament
- ISO 27001 – Information Security Management
Furthermore, we strive to address identified risks in collaboration with our suppliers and support improvements in their policies, competencies, and procedures. We also encourage our suppliers to collaborate with their own suppliers, and to pass on our expectations and to promote good practices throughout the entire supply chain.
We regularly monitor and assess the effectiveness of our preventive measures to identify and continuously implement possible improvements.
Grievance Procedure:
We have established an effective grievance procedure for gathering information on human rights and environmental risks that occur in our business operations and supply chain. We have also appointed a Complaints Officer and a Complaints Team. We have regulated further details in the publicly accessible rules of procedure in accordance with Section 8 (2) LkSG.
In designing and implementing this procedure, we particularly focus on the following characteristics:
- Clarity and easy accessibility for anyone who wants to report concerns or suspicions regarding possible human rights and environmental risks in our own business operations and supply chain.
- Confidential handling of all reports, with due care for the privacy and safety of the reporting person.
- Preliminary assessment of reports to determine whether they relate to a potential human rights or environmental risk in our supply chain or our own business operations.
- Thorough investigation of all human rights and environmental grievances and taking appropriate remedial actions to address identified risks.
- Regular feedback to the reporting person on the status of their report and the result of the investigation, as far as this is legally permissible.
- Detailed recording of all reports and investigations, including any remedial measures, and retention of these records.
- Ensuring that whistleblowers are protected from reprisals.
- Training our staff (Complaints Officer and members of the Complaints Team) for responsible and effective handling of reports.
The grievance procedure is accessible in the following way: complains.supply.chain@psi.de.
Continuos Improvemant:
We will regularly review the effectiveness of our risk assessments, our grievance procedure, as well as our prevention and remediation measures, and work towards their continuous improvement. In doing so, we want to ensure that we remain in compliance with relevant laws and international standards on human rights and the environment in the long term.
Berlin, 23.10.2024
PSI Transcom GmbH